EU sanctions decision-making in times of war: Procedural changes and rise of the Commission

EU restrictive measures in response to the Russian full-scale war against Ukraine were enacted in record time, despite the fact that EU sanctions decision-making is known to be lengthy and bureaucratic. How could the EU so swiftly adopt restrictions that severely disrupted its economic ties with its fifth largest trade partner? The speed of the EU’s response is due, among other things, to the unusually proactive stance taken by the European Commission. In the context of post-invasion sanctions against Russia, often extended to Belarus, the Commission exercised unprecedented power to shape sanctions proposals, build compromises in the Council of the EU and develop the EU sanctions toolbox. The present contribution explores the procedural arrangement at the core of the EU sanctions decision-making that enabled the Commission to step into this intergovernmental field. On the basis of data collected via interviews and publicly available sources, the article demonstrates that there is a growing gap between the conventional way of sanctions law-making and real power dynamics within the EU institutional framework. The ‘crisis trigger’ makes the EU move beyond intergovernmentalism in its sanctions policy.